Nutrition Assistance Program Report Series
The Office of Policy Support
Special Nutrition Programs Report No. CN-14-DC
Direct Certification in the National
School Lunch Program:
State Implementation Progress,
School Year 2013–2014
Report to Congress
May 2015 Special Nutrition Programs Report Number: CN-14-DC
Direct Certification in the National School Lunch Program:
State Implementation Progress, School Year 2013–2014
Report to Congress
Authors: Quinn Moore Kevin Conway Brandon Kyler Andrew GothroSubmitted by: Submitted to:
Mathematica Policy Research Office of Policy Support
P.O. Box 2393 USDA Food and Nutrition Service
Princeton, NJ 08543-2393 3101 Park Center Dr., Room 1014
Telephone: (609) 799-3535 Alexandria, VA 22302-1500
Facsimile: (609) 799-0005
Project Director: Project Officer:
Kevin Conway Dennis Ranalli
Deputy Project Director:
Quinn Moore
This study was conducted under GSA Contract AG-3198-B-10-0013, task order AG-3198-K-14-0012 with the Food and Nutrition Service.
This report is available on the Food and Nutrition Service website: http://www.fns.usda.gov/research-and-analysis
Suggested Citation:
U.S. Department of Agriculture, Food and Nutrition Service, Office of Policy Support, Direct Certification in the
National Lunch Program: State Implementation Progress, School Year 2013–2014 by Quinn Moore, Kevin
Conway, Brandon Kyler, and Andrew Gothro. Project Officer Dennis Ranalli. Report CN-13-DC. Alexandria, VA: May 2015.
ABSTRACT
This report responds to the legislative requirement of the Food, Conservation, and Energy Act of 2008 (P.L.110-234) to assess the effectiveness of State and local efforts to directly certify children for free school meals under the National School Lunch Program (NSLP). Direct
certification is a process conducted by the States and by local education agencies (LEAs) to certify certain children for free school meals without the need for household applications. The Child Nutrition and WIC Reauthorization Act of 2004 required all LEAs to establish, by school year (SY) 2008–2009, a system of direct certification of children from households that receive Supplemental Nutrition Assistance Program (SNAP) benefits. The Healthy, Hunger-Free Kids Act of 2010 (HHFKA) requires that States meet certain direct certification performance targets. For SY 2013–2014, States that fail to achieve a direct certification rate of at least 95 percent are required to develop and implement continuous improvement plans. The performance target will remain at 95 percent in future years.
Ninety-three percent of LEAs that participate in the NSLP directly certified some SNAP participants and other categorically eligible students in SY 2013–2014. These LEAs enroll 99 percent of all students in schools that participate in the NSLP. This is an increase from SY 2004– 2005, when 56 percent of LEAs, enrolling 77 percent of all students in NSLP schools, directly certified some categorically eligible students.
The number of school-age SNAP participants directly certified for free school meals was 12.4 million for SY 2013–2014, an increase of 1 percent from SY 2012–2013. This year the methodology for calculating the direct certification performance rate was refined in order to make use of new data elements collected in the revised Verification Collection Report (FNS-742) and the new Direct Certification Rate Data Element Report (FNS-834). Therefore, direct certification performance rates presented in this report are not directly comparable to those in reports from prior years.
The results of the analysis in this report indicate that 87 percent of children in SNAP households were directly certified for free school meals. Twelve States achieved the HHFKA-mandated performance target of 95 percent, and no States had a direct certification rate lower than 60 percent.1
1 Although Hawaii’s performance rate exceeded 95 percent, the State was not able to distinguish students directly
certified based on SNAP benefit receipt from those based on other program participation. For this reason, Hawaii is not considered to have met the HHFKA-mandated performance target.
CONTENTS
ABSTRACT ... v
GLOSSARY OF ACRONYMS AND ABBREVIATIONS ... ix
EXECUTIVE SUMMARY ... xi
DIRECT CERTIFICATION IN THE NATIONAL SCHOOL LUNCH PROGRAM: STATE IMPLEMENTATION PROGRESS, SCHOOL YEAR 2013–2014 ... 1
I. Introduction ... 1
A. Eligibility determination through application ... 1
B. Eligibility determination through direct certification ... 2
C. Purpose of this report ... 2
II. History of direct certification ... 3
III. Current status of direct certification systems ... 4
A. Characteristics of LEAs that did not directly certify any SNAP children ... 9
IV. Direct certification performance ... 9
A. Data limitations and special circumstances affecting direct certification performance measurement ... 10
B. Calculations of State direct certification performance ... 12
C. Comparison with SY 2012-2013 direct certification performance ... 15
V. Direct certification best practices ... 21
A. Description of State practices ... 21
B. Recent and planned strategies for improving direct certification ... 32
C. Best practices in implementation of direct certification systems ... 34
D. Challenges in meeting performance rate targets ... 36
VI. Conclusion ... 39
VII.References ... 41 APPENDIX A: ADDITIONAL TABLES AND FIGURES
APPENDIX B: SCHOOL FOOD AUTHORITY VERIFICATION COLLECTION REPORT (FORM FNS-742) AND STATE AGENCY (NSLP/SNAP) DIRECT CERTIFICATION RATE DATA ELEMENT REPORT (FORM FNS-834)
APPENDIX C: DESCRIPTION AND LIMITATIONS OF DATA SOURCES USED FOR DIRECT CERTIFICATION PERFORMANCE MEASURE CALCULATIONS
TABLES
1 Number and percent of LEAs that directly certified categorically eligible students, SY
2011–2012 through SY 2013–2014 ... 6
2 SNAP participation, direct certifications, and SNAP-participant students in special provision schools in a non-base-year, SY 2013–2014 (thousands) ... 11
3 Students eligible for direct or categorical certification: Number directly certified and number approved by application, SY 2013–2014 (thousands) ... 19
4 Characteristics of the direct certification matching process for public LEAs in selected States, SY 2013–2014 ... 23
5 Primary matching criteria for States that use central matching systems ... 25
6 Approach for children with potential matches and for children not matched in the primary process ... 30
7 Direct certification methods for private and charter schools ... 31
8 Recent and planned strategies for improving direct certification ... 33
9 Suggestions for improving direct certification rates ... 35
10 Challenges identified by States in meeting direct certification rate target ... 37
FIGURES 1 Percent of LEAs that directly certified categorically eligible students and percent of students in LEAs that directly certified categorically eligible students, SY 2004–2005 through SY 2013–2014 ... 5
2 Percent of LEAs that directly certified categorically eligible students and percent of students in LEAs that directly certified categorically eligible students by enrollment category, SY 2013–2014... 8
3 Percent of LEAs and students, by enrollment category, SY 2013–2014 ... 8
4 Percent of school-age SNAP-participant children directly certified for free school meals, SY 2013–2014 ... 13
5 Number of States meeting direct certification performance target set by the Healthy, Hunger-Free Kids Act, SY 2013–2014 ... 14
6 Number of States with direct certification performance rates above or below the mandated performance targets, by region, SY 2013–2014 ... 15
7 Percent of SNAP-participant children directly certified for free school meals, by State ... 16
GLOSSARY OF ACRONYMS AND ABBREVIATIONS
ACS American Community Survey (U.S. Census Bureau)
ARC Arkansas Research Center
BBCE broad-based categorical eligibility
CE categorical eligibility
CEP Community Eligibility Provision
CIP continuous improvement plan
CN child nutrition
DER Direct Certification Rate Data Element Report (FNS Form 834)
DHHS U.S. Department of Health and Human Services
DOB date of birth
FCEA Food, Conservation, and Energy Act of 2008
FDPIR Food Distribution Program on Indian Reservations
FNS Food and Nutrition Service
FY fiscal year
HHFKA Healthy, Hunger-Free Kids Act of 2010
ID identification
IT information technology
LEA local education agency
MDE Minnesota Department of Education
MDHS Minnesota Department of Human Services
NCDOE North Carolina Department of Education
NHDOE New Hampshire Department of Education
NSLA Richard B. Russell National School Lunch Act
NSLP National School Lunch Program
P.L. Public Law
SBP School Breakfast Program
SDE State Department of Education (Idaho)
SIPP Survey of Income and Program Participation
SFA school food authority
SNAP Supplemental Nutrition Assistance Program
SSIS statewide student information system
SSN Social Security number
SY school year
TANF Temporary Assistance for Needy Families
USDA U.S. Department of Agriculture
VCR Verification Collection Report (FNS Form 742)
EXECUTIVE SUMMARY
This report responds to a legislative requirement of the Food, Conservation, and Energy Act of 2008 (FCEA) (Public Law [P.L.] 110-234, also known as the 2008 Farm Bill) to assess the effectiveness of State and local efforts to directly certify children for free school meals under the National School Lunch Program (NSLP). The 2008 Farm Bill requires annual Reports to
Congress. This is the seventh report in the series, covering school year (SY) 2013–2014. The Food and Nutrition Service (FNS) will use results from this report in determining performance awards and identifying those States that must develop and implement direct certification improvement plans (CIPs), as required by Section 101 of the Healthy, Hunger-Free Kids Act (HHFKA) of 2010 (P.L. 111-296). For this report, the methodology for calculating direct certification performance was refined from the methodology used in previous reports in order to make use of new data elements collected in the revised Verification Collection Report (FNS-742) and the new Direct Certification Rate Data Element Report (FNS-834).
The NSLP reimburses local education agencies (LEAs) for the cost of providing nutritious meals to children in public and private schools and residential child care institutions. Average daily participation across NSLP schools and institutions totaled approximately 31 million children in fiscal year (FY) 2013.
Participating schools and institutions receive cash reimbursements and foods donated by the U.S. Department of Agriculture (USDA) for each meal served. In exchange for Federal
assistance, schools must serve meals that meet USDA nutrition and food safety standards. In addition, participating schools must serve meals at no cost or at reduced price to income-eligible children.
Eligibility for program benefits
Children from households with incomes at or below 130 percent of the Federal poverty level are eligible for free school meals. Children from households with incomes no greater than 185 percent of the Federal poverty level are eligible for reduced-price meals. All NSLP meals are subsidized by USDA, including those served to children with household incomes above 185 percent of the Federal poverty level. The subsidies provided for free and reduced-price meals are substantially larger than the subsidies provided for full-price meals.
Children from households that receive benefits under certain other Federal assistance programs are deemed categorically eligible for free meals under the NSLP. Participation in the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), or the Food Distribution Program on Indian Reservations (FDPIR) confers categorical eligibility for free meals. Effective with the start of SY 2009–2010, if one child in a household participating in one of these assistance programs is directly certified (see the next section) or is determined categorically eligible for free school meals by application, then all children in that household are categorically eligible for free meals.
In addition, certain children who are migrants, runaways, or homeless; who are in foster care; or who are enrolled in Head Start or Even Start are categorically eligible for free school meals. However, their eligibility does not extend to other children in their household.
Direct certification
Students’ eligibility for free meals is determined by application or by direct certification. The Child Nutrition and WIC Reauthorization Act of 2004 (the 2004 Reauthorization Act) required all States to establish a system of direct certification of school-age SNAP participants by SY 2008–2009. The requirement applies only to children participating in SNAP; however, States and LEAs may also directly certify children from TANF and FDPIR households.
Although direct certification systems vary by State and LEA, all such systems substantially reduce the need for household applications. Many States and LEAs certify categorically eligible students through computer matching of program records against student enrollment lists. Those systems require no action by the children’s parents or guardians. States and LEAs commonly incorporate participation data from programs other than SNAP, such as TANF, FDPIR, or foster care. In some States, SNAP, TANF or FDPIR agencies send letters to program participants indicating that any school-age children in the household are eligible for free school meals. Household members can forward these letters to LEA staff in order to be certified without an application. In the past, States and LEAs could consider these children directly certified. However, effective with SY 2012–2013, States may no longer use the letter method as a means of direct certification for SNAP, although they are required to continue to accept such letters in lieu of applications as documentation of categorical eligibility.
HHFKA requires that States meet certain direct certification performance targets. For SY 2013–2014, States that fail to achieve a direct certification rate of at least 95 percent are required to develop and implement CIPs. The performance target will remain at 95 percent in future years.
State performance measures
This report presents information on direct certification performance for SY 2013–2014. As noted above, the methodology for calculating the performance measure was refined for this report to make use of new data elements from the revised Verification Collection Report (FNS-742) and the new Direct Certification Rate Data Element Report (FNS-834). In order to calculate the performance rate, Mathematica Policy Research used State-reported counts of the number of school-age SNAP participants, the number of children directly certified for free school meals based on SNAP participation, and the number of SNAP children in special provision schools operating in non-base years. The refined formula provides a measure of the success of State and local systems to directly certify SNAP-participant children.
Mathematica also calculated the percentage of school-age SNAP, TANF, and FDPIR participants certified for free school meals by direct certification, application, or letter method. This measure provides a more comprehensive assessment of State efforts to ensure that all categorically eligible children are properly certified for free school meals.
Key findings
At the start of SY 2013–2014, States and LEAs directly certified 11.2 million children based on participation in SNAP and 1.2 million children based on participation in programs other than SNAP, for a total of 12.4 million children. This total represents an increase of 1 percent from the previous year. The calculated percentage of SNAP-participant children directly certified for free school meals was 87 percent in SY 2013–2014. The direct certification performance rate in SY 2012–2013 was estimated at 89 percent; however, this estimate was based on different data
sources and overstated the percentage of SNAP-participant children directly certified for free school meals because it included students directly certified based on programs other than SNAP.2
For 38 States in SY 2013–2014, the number of students certified using direct certification, application based on categorical eligibility, or letter method was at least 95 percent of the estimated number of school-age children categorically eligible for free school meals based on participation in SNAP, TANF or FDPIR. However, this measure may overstate the effectiveness of State efforts to ensure that all categorically eligible children receiving SNAP, TANF, or FDPIR benefits are properly certified for free school meals for several reasons. Most
importantly, many States and districts have improved their certification processes to directly or categorically certify categorically eligible children from programs other than SNAP, TANF, or FDPIR, such as those receiving foster care or those directly certified based on Medicaid data in States participating in the Direct Certification-Medicaid demonstration. While these represent important improvements to direct certification systems, they may also have the effect of
overstating the percentage of SNAP, TANF, or FDPIR recipients who were certified because it includes children certified through other programs that allow for direct certification or confer categorical eligibility.
The number of LEAs directly certifying categorically eligible children continues to increase. In SY 2004–2005, before the congressional mandate for direct certification, 56 percent of LEAs directly certified categorically eligible children on a discretionary basis. By SY 2013–2014, 93 percent of LEAs directly certified some categorically eligible children; those LEAs enrolled 99 percent of students in NSLP-participating schools.
State best practices
States and LEAs continue to find success with different direct certification models, and they are making investments in their direct certification systems that promise improved performance in the coming years.
Representatives from six states with successful or improved direct certification systems were interviewed for this report. Four of these States have revised their direct certification matching systems with the help of grant money made available by USDA. Recent direct certification changes that States link to performance improvements include improving data system
capability—such as increasing use of automated processes—and increasing match frequency. Many of these changes were made with an eye toward meeting the performance benchmarks set forth in HHFKA (95 percent in SY 2013–2014 and in future years). In discussions surrounding challenges to meeting these benchmarks in future years, States frequently cited difficulties inherent in matching data from different sources, such as divergent file layout and data entry protocols across data sources. States also cited the inability of direct certification improvement measures to account for children who receive SNAP benefits but who are not enrolled in schools
2 An estimate that more closely approximates the estimates used in previous reports can by calculated by including
the counts of both SNAP and non-SNAP direct certifications from the revised FNS-742. Instead of a national direct certification rate of 87 percent found using the primary method, this alternate method generates a 95 percent national rate—6 percentage points higher than the rate in last year’s report. While it is important to not misinterpret this figure, it helps to confirm that States continue to improve their direct certification performance.
and thus not eligible for direct certification. These students include home-schooled children, school dropouts, and some homeless and migrant children.
Conclusion
States and LEAs have made significant progress in complying with the 2004
Reauthorization Act. An estimated 93 percent of LEAs, enrolling 99 percent of all children in NSLP-participating schools, directly certified SNAP participants in SY 2013–2014. Eighty-seven percent of children from SNAP-participant households were directly certified for free school meals in SY 2013–2014. Twelve States achieved direct certification rates of at least 95 percent, the direct certification performance target set by HHFKA for SY 2013–2014. No States had a direct certification rate lower than 60 percent.
DIRECT CERTIFICATION IN THE NATIONAL SCHOOL LUNCH PROGRAM: STATE IMPLEMENTATION PROGRESS, SCHOOL YEAR 2013–2014
I. Introduction
The National School Lunch Program (NSLP) reimburses local education agencies (LEAs) for the cost of providing nutritious low-cost or free meals to children in public and private schools and residential child care institutions. Participating schools and institutions receive cash reimbursements and foods donated by the U.S. Department of Agriculture (USDA) for each meal served. About 100,000 schools and institutions participate in the program. Average daily student
participation totaled about 31 million in fiscal year (FY) 2013.3
In exchange for Federal assistance, participating schools and institutions serve meals that satisfy Federal nutrition and food safety standards. In addition, they must offer school meals at no cost, or at reduced price, to eligible children. Children from households with incomes at or below 130 percent of the Federal poverty level ($30,615 for a family of four during school year
(SY) 2013–2014)4 are eligible for free meals. Those from households with incomes from 130 to
185 percent of the Federal poverty level ($43,568 for a family of four during SY 2013–2014) are eligible for reduced-price meals. Students are determined eligible for free meals through
application or direct certification (described next); reduced-price eligibility is determined by application alone.
A. Eligibility determination through application
Most LEAs accept applications from households to establish the eligibility of the children
who reside in them for free or reduced-price school meals.5 Most applicants submit self-declared
income and household size information, which is compared with the income thresholds for free and reduced-price benefits. Other applicants provide case numbers that demonstrate household participation in one of several other means-tested Federal assistance programs. Children in households that receive benefits under the Supplemental Nutrition Assistance Program (SNAP), Temporary Assistance for Needy Families (TANF), or Food Distribution Program on Indian Reservations (FDPIR) are categorically eligible for free school meals. Categorical eligibility through these assistance programs, whether determined by application or by direct certification (described next), extends to all children in the same household. Foster children; certain children enrolled in Federally funded Head Start or Even Start programs; and certain homeless, runaway, and migrant children are also categorically eligible for free school meals. Their eligibility is on an individual basis and does not extend to other children in the household.
3 See http://www.fns.usda.gov/sites/default/files/NSLPFactSheet.pdf.
4 The income eligibility thresholds given here apply to households from the 48 contiguous States, the District of
Columbia, Guam, and the other U.S. territories. The income thresholds are higher in Alaska and Hawaii. A table of income eligibility thresholds can be found at http://www.fns.usda.gov/sites/default/files/RPieg.pdf.
5 Some schools receiving reimbursements under special provisions do not collect applications. These include
schools using Provisions 2 or 3 and operating in a non-base year, as well as schools using the new Community Eligibility Provision.
B. Eligibility determination through direct certification
Direct certification confirms a child’s categorical eligibility for free school meals without the need for a household application. Direct certification typically involves matching SNAP,
TANF, and FDPIR records against student enrollment lists, at either the State or the LEA level.6
Parents or guardians of children identified through these matching systems are notified of their children’s eligibility for free school meals.7 They need not take action for their children to be
certified.8
The 2004 Reauthorization Act requires that each State education agency enter into an agreement with the State agency responsible for determining SNAP eligibility. The agreement must establish procedures to directly certify children from SNAP households for free school
meals.9 States may also directly certify children from TANF and FDPIR households; foster
children; participants in Federally funded Head Start or Even Start programs; and certain homeless, runaway, and migrant children, but are not required to do so.
C. Purpose of this report
This report responds to Section 4301 of the Food, Conservation, and Energy Act of 2008
(FCEA),10 which calls for an assessment of the “effectiveness of each State in enrolling
school-age children in households receiving … [SNAP] benefits” for free school meals.11 Specifically,
the law requires the following:
1. State-level estimates of the number of school-age children who received SNAP benefits at any time in July, August, or September (just before or at the start of the current SY). 2. Estimates of the number of SNAP-participant children who were directly certified for
free school meals as of October 1.
3. Estimates of the number of SNAP-participant students who were not candidates for direct certification because they attended special provision schools operating in years in which applications were not collected.
The Food and Nutrition Service (FNS) will use these estimates in determining performance awards and identifying those States that must develop and implement direct certification
6 Federal law requires direct certification of SNAP-participant children. However, most State direct certification
systems also extend to children in TANF households.
7 Households must be given the opportunity to decline free school meal benefits.
8 In the past, States and LEAs could opt to send letters to SNAP, TANF, and FDPIR households with school-age
children. The letters served as proof of categorical eligibility for free meals and were forwarded by the households to their children’s schools. By SY 2012–2013, States were required to phase out the use of the letter method and it could no longer be used to directly certify children receiving SNAP benefits.
9 The Child Nutrition and WIC Reauthorization Act’s direct certification provision was phased in over a three-year
period beginning with SY 2006–2007.
10 Also known as the 2008 Farm Bill.
11 This report includes analysis of the contiguous United States, Alaska, Hawaii, and Guam.
continuous improvement plans (CIPs), as required by Section 101 of the Healthy, Hunger-Free Kids Act of 2010 (HHFKA) (P.L. 111-296). Specifically, for SY 2013–2014 and beyond, States that fail to achieve a direct certification rate of at least 95 percent are required to develop and implement CIPs. This year, we used a revised methodology to calculate State direct certification performance that makes use of data elements from the Verification Collection Report (VCR), a revised version of FNS Form 742 that replaced the Verification Summary Report in SY 2013– 2014, and the new Direct Certification Rate Data Element Report (DER, FNS Form 834). As a result of the revised methodology, the performance measure now reflects State-reports of key components of the measure and no longer overstates the percentage of SNAP participants who were directly certified by including children directly certified based on participation in other programs.
In addition to presenting direct certification performance measures, Section 4301 of the FCEA also calls for a discussion of best practices in States with successful direct certification systems.
II. History of direct certification
In the mid-1980s, program managers and policymakers recognized a duplication of effort in certifying school children for free meals under the NSLP and the School Breakfast Program
(SBP),12 and certifying families for what are now the SNAP and TANF programs (formerly the
Food Stamp Program and Aid to Families with Dependent Children, respectively). All these programs have similar income-eligibility limits, and many school children participated in more than one. Further, the application processes for SNAP and TANF were, and remain, more detailed and rigorous than the certification process for free meals under the NSLP. Use of eligibility determinations for SNAP and TANF could improve the accuracy of certifications for NSLP.
Legislation taking a first step to link these programs was enacted in 1986. The Richard B. Russell National School Lunch Act (NSLA) was amended to make children who are members of a household receiving assistance under SNAP and TANF automatically eligible for free school meals. This action paved the way for more simplified application and certification procedures for these children. Initially, families could put their case number from these programs on the
application in lieu of providing income information.13 Then, in 1989, P.L. 101-147 (Child
Nutrition and WIC Reauthorization Act of 1989) allowed school food authorities (SFAs) to certify children, without further application, by directly communicating with the appropriate State or local agency to obtain documentation that the children were members of a household receiving either SNAP or TANF benefits. This first statutory authorization of direct certification was made optional for SFAs.
12 Children certified for free or reduced-price meals under the NSLP are eligible for free or reduced-price breakfasts
under the SBP. The two programs share a single application process. Throughout this report, certification for free or reduced-price benefits under the NSLP should be understood to mean certification for the SBP as well.
13 The option to provide a case number on the application has been retained to enable the LEAs to more easily
process children who were not directly certified.
The 2004 Reauthorization Act amended the NSLA to mandate direct certification with SNAP for all LEAs. Before 2004, the NSLA referred only to SFAs when describing local administration of the NSLP. With the 2004 Reauthorization Act, the NSLA recognized LEAs,
rather than SFAs, as the entities responsible for NSLP application and certification processes.14
The 2004 act retained discretionary authority for TANF direct certification. Mandatory direct certification with SNAP was phased in over three years, beginning in SY 2006–2007. All LEAs, including private schools, were required to have direct certification systems in place for SY 2008–2009.
Because State agencies administering the NSLP and SBP recognized that direct certification would increase participation, ease the burden on families and LEAs, and result in more accurate targeting of free school meal benefits, many States chose to phase in the use of direct
certification in advance of the mandate. State education agencies worked in partnership with the agencies in their States that administered SNAP and TANF. At the outset, various methods were used, refined, and expanded. By the time direct certification with SNAP became mandatory, many State agencies had systems in place and were familiar with the process.
In the years since the statutory mandate, additional implementation requirements have been introduced with the intention of increasing the reach and effectiveness of direct certification. In August 2009, FNS issued guidance requiring that free meal eligibility apply to all children in a household if at least one child is certified for free meals based on receipt of SNAP, TANF, or FDPIR benefits. HHFKA required that State agencies no longer use the letter method as a means of direct certification with SNAP. This act also includes a provision that expands direct
certification to include Medicaid in some districts via a demonstration project. In addition, starting in SY 2011–2012, FNS required that direct certification matching with SNAP records occurs at least three times per school year.
Even though all LEAs are now subject to the statutory direct certification mandate, there continues to be a need for household applications. Some households with incomes at or below 130 percent of the Federal poverty level do not participate in SNAP. Children from those
households remain income-eligible for free school meals, but will not be identified through direct certification. In addition, because children from households with incomes from 130 to 185 percent of the Federal poverty level are not eligible for SNAP, direct certification cannot be used to certify children eligible for reduced-price school meals.
III. Current status of direct certification systems
The 2004 Reauthorization Act required that all LEAs begin directly certifying children from SNAP-participant families by SY 2008–2009. The direct certification mandate was phased in over three years. LEAs with total enrollments of 25,000 or more students were required to establish direct certification systems no later than SY 2006–2007. LEAs with enrollments of 10,000 or more followed in SY 2007–2008. Phase-in was complete in SY 2008–2009, when all LEAs were subject to the statutory mandate.
14 This report focuses on the role LEAs play in certifying students for free school meals. We use the terms LEA and
district interchangeably.
Figure 1 and Table 1 illustrate the increases over time in both the percentage of LEAs that directly certified categorically eligible students—SNAP-participants and participants in other programs that allow for direct certification—and the percentage of students enrolled in those LEAs. For SY 2013–2014, 93 percent of LEAs directly certified some categorically eligible students, and those LEAs enrolled 99 percent of all students in NSLP-participating schools. Figure 1. Percent of LEAs that directly certified categorically eligible students and percent of students in LEAs that directly certified categorically eligible students, SY 2004–2005 through SY 2013–2014
Note: The data for SY 2013–2014 are from the VCR form, which breaks out students directly certified through SNAP and through other programs. Districts that directly certified SNAP participants and/or other program participants are included in this count, as are districts that are not required to conduct direct certification. In SY 2013-2014, about 2 percent of districts were required to conduct direct certification and directly certified no SNAP participants but did directly certify some students based on participation in other programs. In previous years, the data were not broken out by program and might also include other students who were not directly certified, but were not subject to verification.
56% 60% 63% 67% 78% 83% 85% 89% 91% 93% 77% 81% 86% 89% 95% 97% 97% 98% 99% 99% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% 2004-2005 2005-2006 2006-2007 2007-2008 2008-2009 2009-2010 2010-2011 2011-2012 2012-2013 2013-2014 Pe rc en t School Year
Percent of LEAs that directly certified some categorically eligible students
Table 1. Number and percent of LEAs that directly certified categorically eligible students, SY 2011–2012 through SY 2013–2014 SY 2011–2012 SY 2012–2013 SY 2013–2014 Direct certification or Provision 2/3 LEAs Direct certification or Provision 2/3 LEAs Direct certification or special provision LEAs Number
of LEAs Number Percent
Number
of LEAs Number Percent
Number
of LEAs Number Percent
U.S. Total 18,643 16,545 88.7 18,362 16,684 90.9 19,707 18,423 93.5 Alabama 156 145 92.9 159 152 95.6 191 149 78.0 Alaska 50 49 98.0 69 48 69.6 68 68 100.0 Arizona 456 404 88.6 464 407 87.7 489 479 98.0 Arkansas 289 279 96.5 284 268 94.4 312 302 96.8 California 1,094 872 79.7 1,094 1,024 93.6 1,295 1,227 94.7 Colorado 214 204 95.3 209 201 96.2 231 224 97.0 Connecticut 185 183 98.9 188 186 98.9 202 197 97.5 Delaware 42 35 83.3 44 40 90.9 48 47 97.9 District of Columbia 61 60 98.4 63 63 100.0 67 67 100.0 Florida 223 178 79.8 226 185 81.9 277 261 94.2 Georgia 229 219 95.6 222 212 95.5 236 232 98.3 Guam 3 1 33.3 2 1 50.0 3 2 66.7 Hawaii 35 25 71.4 35 35 100.0 35 34 97.1 Idaho 148 141 95.3 149 149 100.0 162 159 98.1 Illinois 1,126 1,039 92.3 1,051 984 93.6 1,152 983 85.3 Indiana 496 429 86.5 504 447 88.7 550 539 98.0 Iowa 477 428 89.7 474 419 88.4 487 456 93.6 Kansas 400 362 90.5 398 378 95.0 415 402 96.9 Kentucky 189 178 94.2 188 186 98.9 200 199 99.5 Louisiana 113 106 93.8 114 107 93.9 140 130 92.9 Maine 187 170 90.9 189 182 96.3 205 192 93.7 Maryland 55 47 85.5 55 38 69.1 67 58 86.6 Massachusetts 422 355 84.1 363 324 89.3 464 448 96.6 Michigan 845 762 90.2 847 784 92.6 876 848 96.8 Minnesota 697 472 67.7 694 458 66.0 690 534 77.4 Mississippi 175 159 90.9 172 159 92.4 186 168 90.3 Missouri 755 704 93.2 762 711 93.3 777 737 94.9 Montana 240 212 88.3 239 206 86.2 239 215 90.0 Nebraska 374 320 85.6 370 337 91.1 391 378 96.7 Nevada 20 15 75.0 25 17 68.0 32 28 87.5 New Hampshire 100 88 88.0 98 82 83.7 107 106 99.1 New Jersey 697 683 98.0 699 680 97.3 729 717 98.4 New Mexico 202 147 72.8 205 143 69.8 222 113 50.9 New York 1,101 1,001 90.9 1,093 942 86.2 1,124 1,014 90.2 North Carolina 162 152 93.8 161 152 94.4 177 176 99.4 North Dakota 203 179 88.2 202 174 86.1 207 195 94.2 Ohio 1,214 1,043 85.9 1,219 1,146 94.0 1,305 1,270 97.3 Oklahoma 573 545 95.1 572 548 95.8 604 587 97.2 Oregon 244 205 84.0 239 204 85.4 280 256 91.4 Pennsylvania 853 768 90.0 853 790 92.6 894 854 95.5 Rhode Island 54 49 90.7 53 53 100.0 79 71 89.9 South Carolina 106 84 79.2 94 84 89.4 148 132 89.2 South Dakota 210 194 92.4 208 189 90.9 219 211 96.3 Tennessee 183 174 95.1 182 174 95.6 195 193 99.0 Texas 1,259 1,148 91.2 1,247 1,154 92.5 1,251 1,160 92.7 Utah 85 81 95.3 94 94 100.0 103 103 100.0 Vermont 218 203 93.1 88 82 93.2 92 79 85.9 Virginia 155 146 94.2 151 145 96.0 173 168 97.1 Washington 326 296 90.8 319 300 94.0 337 321 95.3 West Virginia 72 57 79.2 71 58 81.7 96 93 96.9 Wisconsin 812 698 86.0 799 728 91.1 809 777 96.0 Wyoming 58 51 87.9 62 54 87.1 69 64 92.8
Note: Figures for school years before SY 2013–2014 may differ from previous reports due to changes in data submitted by States.
About two-thirds of the LEAs that did not directly certify categorically eligible students in SY 2013–2014 are private, and three-quarters are single-school LEAs. These schools might be less likely to enroll categorically eligible children or could face greater barriers to implementing direct certification. The information-sharing relationship between private school LEAs and the States’ education agencies often differs from the relationship between public LEAs and the States. For this reason, private LEAs are sometimes excluded from State-level direct certification matching systems. Although small, single-school, and private LEAs might face special
challenges in setting up direct certification systems, all are subject to the statutory mandate. The 2004 Reauthorization Act’s phased implementation of mandatory direct certification recognized that the fixed costs of establishing such a system would pose the greatest challenge to small LEAs. Although SY 2013–2014 is the sixth year that the smallest LEAs were subject to the statutory mandate, these LEAs continue to lag behind larger LEAs somewhat in adopting direct certification, and it remains useful to track the progress of that group separately.
Figure 2 shows estimates by LEA enrollment category of the percentage of LEAs that directly certified categorically eligible students and the percentage of students enrolled in LEAs that directly certified categorically eligible students in SY 2013–2014. Use of direct certification is nearly universal for larger LEAs; 99 percent of LEAs with enrollments of 5,000 or more students, 98 percent of those with enrollments of 1,000 to 4,999, and 97 percent of those with enrollments of 500 to 999 directly certified some categorically eligible students in SY 2013– 2014. Although LEAs with enrollments of at least 500 make up about 52 percent of all LEAs, they enroll about 96 percent of students nationwide (Figure 3).
Direct certification is somewhat less prevalent among small LEAs; about 89 percent of LEAs with fewer than 500 students directly certified categorically eligible students in SY 2013– 2014. Some of the LEAs might not have categorically eligible children among their enrollments, though it is also possible that technical or administrative challenges are among the reasons that these LEAs did not directly certify any categorically eligible students. The direct certification numbers for these small LEAs are a 5-percentage point improvement over the previous year. Therefore, the gap between the largest LEAs and those with fewer students is narrowing.
About 48 percent of all LEAs enroll fewer than 500 students; these LEAs account for only 3 percent of all enrolled students nationwide (Figure 3). Of the 1.7 million students enrolled in these LEAs, a large majority (91 percent) are enrolled in LEAs that directly certified at least some SNAP-eligible children.
Figure 2. Percent of LEAs that directly certified categorically eligible students and percent of students in LEAs that directly certified categorically eligible students by enrollment category, SY 2013–2014
Note: The percentages in this figure are rounded. For example, 99.7 percent of LEAs with 10,000 or more students directly certified some categorically eligible students in SY 2013–2014, which is rounded to 100 percent.
Figure 3. Percent of LEAs and students, by enrollment category, SY 2013–2014
89% 96% 98% 99% 99% 91% 97% 99% 99% 100% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100% Fewer than 500
students 500 to 999 students 1,000 to 4,999students 5,000 to 9,999students 10,000 or morestudents
Pe
rc
en
t
Enrollment Category
Percent of LEAs that directly certified some categorically eligible students
Percent of students enrolled in LEAs that directly certified some categorically eligible students
48% 4% 15% 4% 27% 25% 5% 14% 5% 53% 0% 10% 20% 30% 40% 50% 60% 70% 80% 90% 100%
Percent of all LEAs Percent of all students
Pe
rc
en
t
Fewer than 500 students 500 to 999 students 1,000 to 4,999 students 5,000 to 9,999 students 10,000 or more students
A. Characteristics of LEAs that did not directly certify any SNAP children
Overall, 1,284 LEAs, about 7.0 percent of the total, did not directly certify SNAP-participant children in SY 2013–2014 (a decrease from 1,678 LEAs in SY 2012–2013).
Although the NSLA does not exempt small or single-school districts from the direct certification requirement, both groups are overrepresented among LEAs with no directly certified students. Because they tend to be small, the 7.0 percent of LEAs that did not directly certify any SNAP children enroll only 1.4 percent of students in NSLP-participating schools.
Some additional details on LEAs that did not directly certify SNAP-participant students include the following:
• About 83 percent enrolled fewer than 500 students; only 45 percent of LEAs that did
directly certify SNAP participants enrolled fewer than 500 students.
• About 74 percent are single-school LEAs; only 37 percent of LEAs that did directly certify
SNAP participants are single-school LEAs.
• An estimated 63 percent are private LEAs; only 20 percent of LEAs that did directly certify
SNAP participants are private.
• About 24 percent certified no students at all for free meals, either by direct certification or
by application. FNS has no reason to believe that this small group of about 303 LEAs is not in full compliance with the direct certification requirement; these LEAs might enroll very few or no children from SNAP-participant households.
• About 38 percent certified some but no more than 5 percent of their enrolled students for
free meals; only 11 percent of LEAs that did directly certify SNAP participants reported having such a low concentration of students from low-income households. These LEAs have an unusually low concentration of students certified for free meals, and some might also be in compliance with the direct certification requirement, though their systems failed to identify any SNAP participants.
IV. Direct certification performance
For each State, Mathematica calculates a direct certification performance measure reflecting the percentage of school-age children in SNAP-participant households who were directly
certified for free school meals. For this Report to Congress, the data sources of the components of this measure have changed in important ways from those used in previous Reports to
Congress:
1. The number of SNAP participants directly certified by the State’s LEAs for free school
meals. This value is based on LEA reports on the VCR. For SY 2013–2014, the VCR was
revised such that LEAs report direct certifications from SNAP separately from direct certifications based on other programs.
2. The number of SNAP participants in the State’s non-base year special provision
schools. This value is based on State reports on the DER. In previous Reports to Congress,
this value was estimated based on secondary data sources.
3. The number of school-age children in the State’s SNAP-participant households. This value is based on State reports on the DER. In previous Reports to Congress, this value was estimated based on secondary data sources.
Table 2 provides the values of these components for each State. To take advantage of the new data sources and data reported directly from States, this report’s primary measure of State direct certification effectiveness is computed as follows:
Percent of SNAP children directly certified for free
school meals
=
Students directly certified for free school meals based
on SNAP participation +
SNAP children in special provision schools operating in
non-base years School-age children in SNAP households
Although the revised methodology is more straightforward than the one used in previous reports and addresses many of the limitations of the previous methodology, some limitations to
measuring direct certification performance remain. These limitations are discussed in the next section.
A. Data limitations and special circumstances affecting direct certification performance measurement
The reliability of the performance measure depends on the accuracy of the underlying data. One source of potential inaccuracy is reporting error. For example, if some districts provide inaccurate counts of students who are directly certified based on SNAP participation, then State calculations of students directly certified based on SNAP participation are incorrect—
specifically this inaccuracy will affect the numerator of the performance rate equation. Reporting error can also occur if State agencies provide inaccurate counts of the number of school-age children in SNAP households or SNAP participants in special provision schools operating in non-base years. Reporting error in these counts may be particularly relevant for SY 2013-2014 counts because this is the first year that agencies have used the DER. It is likely that reporting error will decline in future years as agencies become more familiar with the steps needed to complete the form.
To identify potential data limitations, FNS asked States to indicate special circumstances in
the data they submitted that would affect their performance rates.15 Fourteen States cited such
circumstances. FNS discussed these circumstances in detail with staff from the States, obtaining useful information about the challenges States face when collecting the data elements FNS requires. Special circumstances fell into two categories. The first stemmed from data system limitations. Specifically, seven States reported that their data systems prevented them from distinguishing direct certifications based on SNAP from direct certifications based on
participation in programs other than SNAP.16 The resulting performance rates calculated for
these States, therefore, overstate their actual performance.
The second type of special circumstance States cited dealt with children in households receiving SNAP benefits who do not attend schools participating in the NSLP. These children
15 States used the DER form to report these special circumstances, and many of those circumstances pertained to
limitations of the VCR data. See Appendix C for more details.
16 Arizona, California, Connecticut, Hawaii, Ohio, Rhode Island, and Vermont could not distinguish direct
certifications based on SNAP participation from direct certifications based on participation in programs other than SNAP.
Table 2. SNAP participation, direct certifications, and SNAP-participant students in special provision schools in a non-base-year, SY 2013–2014 (thousands)
School-age SNAP participants (from DER data)
NSLP direct certifications based on SNAP participation
(from VCR data)
SNAP-participant students in special provision
schools in a non-base year
(from DER data)
U.S. total 15,346.4 11,261.8 2,099.7 Alabama 300.4 254.2 4.2 Alaska 29.7 17.9 8.6 Arizona* 409.1 215.8 36.1 Arkansas 162.6 131.9 12.9 California* 1,661.8 1,037.5 288.9 Colorado 190.8 131.1 0.0 Connecticut* 109.0 69.0 30.0 Delaware 52.0 44.9 4.2 District of Columbia 35.9 9.1 25.3 Florida 937.3 790.8 122.2 Georgia 661.5 394.0 170.2 Guam 17.6 15.7 0.0 Hawaii* 49.2 50.2 0.0 Idaho 79.9 71.3 0.6 Illinois 648.7 457.4 179.7 Indiana 323.2 241.6 24.0 Iowa 135.8 116.0 9.0 Kansas 105.3 102.1 0.0 Kentucky 248.3 160.9 75.6 Louisiana 309.2 270.9 0.0 Maine 59.2 49.6 0.0 Maryland 207.6 203.0 1.2 Massachusetts 226.8 181.1 32.3 Michigan 500.6 285.0 148.7 Minnesota 176.1 168.8 1.4 Mississippi 221.7 166.4 12.3 Missouri 298.1 255.0 0.0 Montana 38.8 23.2 4.0 Nebraska 62.8 43.1 21.7 Nevada 121.8 93.8 12.4 New Hampshire 33.8 27.6 0.0 New Jersey 282.6 263.7 1.4 New Mexico 168.7 67.8 62.7 New York 908.2 544.1 296.0 North Carolina 509.1 506.8 0.0 North Dakota 17.9 12.2 4.9 Ohio* 575.4 399.1 111.6 Oklahoma 173.1 165.5 7.4 Oregon 214.6 148.9 13.7 Pennsylvania 532.1 372.9 77.2 Rhode Island* 43.4 40.9 0.0 South Carolina 287.6 232.5 0.0 South Dakota 35.6 23.5 7.1 Tennessee 415.0 391.6 0.0 Texas 1,673.3 1,104.5 230.2 Utah 97.6 72.2 1.7 Vermont* 23.0 19.8 0.5 Virginia 288.4 263.8 0.0 Washington 309.5 244.0 12.0 West Virginia 98.5 46.5 44.5 Wisconsin 262.1 250.9 2.5 Wyoming 15.6 12.1 0.4
Note: The U.S. total for each column may not equal the sum of the individual State values due to rounding. Asterisks indicate that State was unable to distinguish direct certifications based on SNAP from direct certifications based on participation in programs other than SNAP. The count labeled “direct certifications based on SNAP participation” includes all direct certifications for these States. The true count of direct certifications based on SNAP participation is lower for these seven States.
appear in the denominator of the direct certification performance rate calculation because the children reside in SNAP households. However, they do not appear in the numerator, because the children do not attend school districts that submit VCR forms. The result decreases State
performance rates. States cited children in the following categories:
• Home-schooled students
• Virtual students (who attend classes online)
• Students attending schools that do not participate in the NSLP
• School-age children who do not attend school, including
- School drop-outs
- Students who graduated early
- Children at least five years old but younger than the mandatory school-start age for their State
- Some homeless and migrant children
Although these types of students were cited as a special circumstance to measurement of direct certification performance by a relatively small number of States, this circumstance is likely relevant to all States. It is difficult to gauge the scope of this problem because many States do not collect individual-level data on children in these circumstances. A limited number of States that identified this as an issue offered estimated numbers for some of these populations. This
provided a useful first step in determining how these challenges affect State performance. However, no firm, comprehensive counts exist for the number of school-age SNAP participants who do not attend school. FNS continues to study the issue with the goal of developing
procedures that would allow for adjustments to the statistics used in the direct certification performance measure in future years. Other limitations of the data and methodology used to calculate State performance rates are discussed in Appendix C.
B. Calculations of State direct certification performance
Figure 4 ranks the States according to this performance measure.17 When examining the
percentage values associated with the States, readers should keep in mind that special
circumstances might affect the measurement of direct certification performance and each of the component statistics of the measure might be subject to reporting error. For this reason, this report focuses primarily on the States’ relative positions in the chart. States near the top of the chart are among the most successful at directly certifying SNAP-participant children for free school meals; relatively few SNAP households in those States are burdened with paper applications. Children from SNAP-participant households in those States are also among the least likely to be misclassified as ineligible for free school meals.
17 Seven States were unable to distinguish direct certifications based on SNAP from direct certifications based on
participation in programs other than SNAP. The direct certification performance rate calculations for these States includes all direct certifications for these States, rather than only those that are based on SNAP. For each of the seven States, then, their rate will overstate their actual performance. The national direct certification rate is not strongly sensitive to the treatment of direct certifications in these States. If we assume that for these States the percentage of direct certifications that were based on SNAP is the same as the median State, the national direct certification performance rate is 86 percent rather than 87 percent.
Figure 4. Percent of school-age SNAP-participant children directly certified for free school meals, SY 2013–2014
Note: Dark green shading indicates calculations that were greater than 100 percent. Light green shading indicates estimates of at least 95 percent and less than or equal to 100 percent. Yellow shading indicates estimates of at least 90 percent and less than 95 percent. Red shading indicates estimates less than 90 percent. Asterisks indicatethat State was unable to distinguish direct certifications based on SNAP from direct certifications based on participation in programs other than SNAP. Performance rate calculations for these States are overstated because they include all direct certifications reported by these States. All seven of these States are shaded as red.
62%69% 70%76% 76%77% 80% 80% 80%81% 81%82% 82%83% 84%85% 85%86% 86% 86%87% 87%88% 88%89% 89%89% 89%90% 91%91% 92%92% 92%94% 94% 94%94% 94%95% 96% 96%97% 97%97% 97%98% 98%100% 100% 100% 100% 0% 20% 40% 60% 80% 100% 120% 140% Arizona* Colorado MontanaOregon Utah New MexicoTexas Wyoming California* Mississippi South Carolina New HampshireIndiana WashingtonMaine PennsylvaniaGeorgia Missouri South DakotaAlabama MichiganNevada Louisiana Vermont*Ohio* Guam Alaska ArkansasIdaho Connecticut*Virginia Iowa West VirginiaNew York New Jersey MassachusettsRhode Island* TennesseeDelaware Kentucky North Dakota District of ColumbiaMinnesota WisconsinKansas FloridaIllinois Maryland North CarolinaOklahoma Hawaii* Nebraska Percent Sta te National Direct Certification Rate: 87 Percent
How to Read This Chart This chart gives estimates of the percent of school age SNAP participants who were directly certified for free school meals for SY 2013-2014.
In Michigan, for example, 87 percent of school-age SNAP participants were directly certified for free school meals. The vertical red line
corresponds to the national direct certification rate.
The States that fall near the bottom of the chart directly certify relatively few participant children. However, by this measure alone, it is not possible to conclude that SNAP-participant children in these States are at particular risk of being denied free meal benefits. LEAs in these States could operate effective school meal application systems. What can be concluded is that SNAP households and LEAs or school administrators in these States are burdened with more administrative paperwork than their counterparts in other States.
The potential for errors in measurement and State reporting minimize the significance of small differences in the percentage point scores of States that fall near one another in Figure 4, but the wide gap between States near the bottom of the chart and those near the top makes clear that some States’ direct certification systems are simply less effective than other States’ systems. Among States and LEAs that rely on computer matching for direct certification, variation in direct certification effectiveness might be explained in part by differences in matching
algorithms, use of probabilistic matching, the nature and quality of data used as input into the matching process, procedures for handling nonmatches, access to a supplemental student-level look-up system, or other system characteristics.
Figure 5 shows the number of States that met or exceeded the direct certification
performance target established by HHFKA—95 percent for SY 2013–2014. Nationally, 12 States
were at or above this benchmark.18 Regionally, there are differences in direct certification
effectiveness (Figure 6). The seven regions shown in Figure 6 are those defined for FNS administrative purposes. The Mid-West, Mountain Plains and Southeast regions have the most States at or above the direct certification performance target in SY 2013–2014 with three each. No States in the Northeast region met the target.
Figure 5. Number of States meeting direct certification performance target set by the Healthy, Hunger-Free Kids Act, SY 2013–2014
18 Although Hawaii’s performance rate exceeded 95 percent, the State was not able to distinguish students directly
certified based on SNAP benefit receipt from those based on other program participation. For this reason, Hawaii is not considered to have met the HHFKA-mandated performance target.
12 40
States Meeting Performance Target States Failing to Meet Performance Target
Figure 6. Number of States with direct certification performance rates above or below the mandated performance targets, by region, SY 2013–2014
Regional differences in direct certification performance can be examined by plotting direct certification rates on a map of the United States. The top panel of Figure 7 shows the SY 2007– 2008 direct certification performance measure for each State, whereas the bottom panel shows the SY 2013–2014 direct certification performance measure. The performance estimate for SY 2007–2008 was based on different data sources than the performance rate for SY 2013–2014 and overstated the percentage of SNAP-participant children directly certified for free school meals because it included students directly certified based on programs other than SNAP. Although the performance calculations used in this report are not directly comparable to the performance estimates from previous years, differences in the two panels in this figure are consistent with a marked increase in direct certification performance over time across all States. This figure also confirms the existence of limited regional differences in State performance.
C. Comparison with SY 2012-2013 direct certification performance
As discussed, the methodology used to calculate this year’s direct certification performance measures includes refinements made possible by the introduction of a revised FNS-742 and the new FNS-834. The revised FNS-742 separates directly certified SNAP participant children from children certified without application through their participation in other assistance programs. In past years, this report relied on a combined figure that tended to overstate SNAP direct
certification rates. This year’s report takes advantage of the SNAP-only figure—the most significant of the methodological changes introduced this year. Although this change allows more precise estimates of SNAP direct certification rates, it generates estimates that are not directly comparable to those produced in the past.
An estimate that more closely approximates the estimates used in previous reports can by calculated by including the counts of both SNAP and non-SNAP direct certifications from the revised FNS-742. Instead of a national direct certification rate of 87 percent found using the
2 3 3 3 1 5 3 7 7 5 4 9 0 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Mid-Atlantic Mid-West Mountain
Plains Northeast Southeast Southwest West
N umb er o f S ta te s Region
States Failing to Meet Performance Target States Meeting Performance Target
Figure 7. Percent of SNAP-participant children directly certified for free school meals, by State
SY 2007–2008
SY 2013–2014
Note: In SY 2013-2014, Arizona, California, Connecticut, Hawaii, Ohio, Rhode Island, and Vermont could not distinguish direct certifications based on SNAP participation from direct certifications based on participation in programs other than SNAP. The resulting performance rates calculated for these States, therefore, overstate their actual performance.
Percent Directly Certified
0 - 59 (13) 60 - 69 (15) 70 - 79 (12) 80 - 89 (6) 90 - 94 (3) 95 + (2)
Percent Directly Certified
0 - 59 (0) 60 - 69 (2) 70 - 79 (4) 80 - 89 (22) 90 - 94 (11) 95 + (13)
primary method, this alternate method generates a 95 percent national rate—6 percentage points higher than the rate in last year’s report. While it is important to not misinterpret this figure, it helps to confirm that States continue to improve their direct certification performance.
A more comprehensive measure of the States’ success in certifying all categorically eligible children for free school meals is developed next. This measure does not attempt to assess the effectiveness of the States’ direct certification systems. Instead, it measures the States’ success at certifying children, directly or by application, based on their participation in or association with any of the programs or institutions that confer categorical eligibility for free school meals.
The measure starts with the number of students who are directly certified based on SNAP participation. This is the same measure of directly certified SNAP participants used in the direct certification performance measure. Added to this are students directly certified based on
participation in a program other than SNAP, students whose approval for free school meals is based on the household’s submission of a SNAP, TANF, or FDPIR case number on an NSLP application, students certified for free school meals based on the letter method, and SNAP children in special provision schools that are operating in non-base years.
This count of children identified as categorically eligible for free meals is divided by an estimate of the combined SNAP, TANF, and FDPIR populations. The SNAP population count used here is the same one used in the performance measure developed earlier. The number of children in households that receive TANF but not SNAP benefits is estimated from data found in the U.S. Census Bureau’s American Community Survey. The number of children who receive FDPIR benefits is estimated from FNS program and survey data.
Details of this computation are summarized in the following equation:
Percent of SNAP, TANF, and FDPIR participants certified (directly or by application) for free school meals = Children directly certified for free school meals based on SNAP + Children directly certified for free school meals based on programs other than SNAP + Children certified for free
school meals based on categorical eligibility by application + Children certified for free school meals through the letter method + SNAP children in special provision schools operating in non-base years School-age children in SNAP households + School-age children in TANF households that do not participate in SNAP + School-age children in FDPIR households
It is important to note that this measure may overstate the effectiveness of State efforts to ensure that all categorically eligible children are properly certified for free school meals for several reasons. Most importantly, many States and districts have improved their certification processes to directly or categorically certify children participating in programs other than SNAP, TANF, or FDPIR, such as those receiving foster care or those directly certified based on
Medicaid data in States participating in the Direct Certification-Medicaid demonstration. While these are important improvements to direct certification systems, they will result in the measure overstating the percentage of SNAP, TANF, or FDPIR recipients who were certified because the measure includes children certified through other programs that allow for direct certification or
confer categorical eligibility. In addition, the components of this measure are subject to reporting and estimation error. Please see Appendix C for further discussion of these limitations.
The components of the numerator and the sum of the values in the denominator are given for each State in Table 3. Figure 8 displays the same data graphically. For the 38 States at the top of Figure 8, the number of students certified using direct certification, application based on
categorical eligibility, or letter method was at least 95 percent of the estimated number of school-age children categorically eligible for free school meals based on participation in SNAP, TANF or FDPIR. States at the bottom of Figure 8 are less successful at identifying and certifying these children.
Table 3. Students eligible for direct or categorical certification: Number directly certified and number approved by application, SY 2013–2014 (thousands)
Number of children identified as categorically eligible Directly certified based on SNAP Directly certified based on other programs Categorically eligible, approved by application or letter method SNAP-participant students in special provision schools in a non-base year U.S. total 16,153.3 11,246.1 1,187.0 1,699.2 2,099.7 Alabama 308.5 254.2 25.2 23.9 4.2 Alaska 36.6 17.9 8.9 1.0 8.6 Arizona 428.1 215.8 0.0 68.1 36.1 Arkansas 167.0 131.9 8.0 8.4 12.9 California 1870.4 1037.5 0.0 323.3 288.9 Colorado 205.6 131.1 16.1 24.8 0.0 Connecticut 117.5 69.0 0.0 15.8 30.0 Delaware 54.3 44.9 3.1 2.0 4.2 District of Columbia 37.6 9.1 0.9 1.2 25.3 Florida 975.8 790.8 177.1 92.8 122.2 Georgia 678.6 394.0 34.9 36.8 170.2 Hawaii 52.8 50.2 0.0 3.9 0.0 Idaho 84.6 71.3 3.5 2.6 0.6 Illinois 683.7 457.4 142.6 35.7 179.7 Indiana 336.1 241.6 16.6 38.4 24.0 Iowa 142.1 116.0 7.3 13.3 9.0 Kansas 110.7 102.1 12.4 3.4 0.0 Kentucky 256.3 160.9 51.4 14.0 75.6 Louisiana 314.7 270.9 11.1 38.0 0.0 Maine 62.2 49.6 3.1 6.1 0.0 Maryland 220.6 203.0 13.6 17.1 1.2 Massachusetts 240.3 181.1 21.4 38.8 32.3 Michigan 521.3 285.0 37.1 51.5 148.7 Minnesota 191.2 168.8 8.4 31.4 1.4 Mississippi 227.2 166.4 8.8 22.6 12.3 Missouri 308.7 255.0 13.6 30.0 0.0 Montana 41.2 23.2 0.8 6.3 4.0 Nebraska 67.0 43.1 5.9 3.9 21.7 Nevada 130.4 93.8 4.9 11.3 12.4 New Hampshire 37.3 27.6 1.8 5.7 0.0 New Jersey 309.2 263.7 14.3 47.4 1.4 New Mexico 175.5 67.8 7.8 19.3 62.7 New York 949.5 544.1 105.3 70.7 296.0 North Carolina 525.6 506.8 23.6 30.5 0.0 North Dakota 19.9 12.2 1.7 1.4 4.9 Ohio 598.9 399.1 0.0 69.7 111.6 Oklahoma 189.5 165.5 13.4 36.3 7.4 Oregon 222.5 148.9 20.8 27.4 13.7 Pennsylvania 567.4 372.9 90.8 35.3 77.2 Rhode Island 45.5 40.9 0.0 6.8 0.0 South Carolina 294.7 232.5 7.8 34.8 0.0 South Dakota 40.2 23.5 1.5 2.7 7.1 Tennessee 427.0 391.6 15.0 12.0 0.0 Texas 1725.1 1104.5 157.4 239.4 230.2 Utah 105.4 72.2 14.0 14.6 1.7 Vermont 24.6 19.8 0.0 3.5 0.5 Virginia 303.5 263.8 14.4 17.9 0.0 Washington 327.1 244.0 41.4 36.3 12.0 West Virginia 101.6 46.5 11.7 1.6 44.5 Wisconsin 275.3 250.9 7.2 18.7 2.5 Wyoming 17.1 12.1 0.6 0.7 0.4
Note: The U.S. total for each column may not equal the sum of the individual State values due to rounding. Counts of students directly certified based on other programs includes those directly certified based on administrative data available through Medicaid in States participating in the Direct Certification-Medicaid demonstration. These students may not be
